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Rowe Entertainment, Inc. v. William Morris Agency et al. (98-8272) -- Declaration of Christine Lepera [Former Attorney to Leonard Rowe and Plaintiffs] [May 14, 2012]

Rowe Entertainment, Inc. v. William Morris Agency et al. (98-8272) -- Declaration of Christine Lepera [Former Attorney to Leonard Rowe and Plaintiffs] [May 14, 2012]

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Published by Mr Alkebu-lan
Third attorney caught lying under oath...
Third attorney caught lying under oath...

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Published by: Mr Alkebu-lan on May 22, 2012
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09/23/2013

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORKROWE ENTERTAINMENT, et al.,
Plaintiff,
Civil Action No. 98 Civ. 8272 (RPP)
- against -
THE WILLIAM MORRIS, et al.,
Defendant.
DECLARATION OF CHRISTINE LEPERAIN RESPONSE TO PLAINTIFF'S FRCPRULE 60 MOTION
Christine Lepera declares under penalty of perjury as follows:
1.
I am a member of the law firm of Mitchell Silberberg & Knupp LLP and am duly
admitted to practice law before this Court. I am not currently representing any party to
this action, nor am I a party to this action.
2.
I respectfully submit this Declaration to assist the Court in reviewing the recently filedmotion by Leonard Rowe, pursuant to Rule 60, Fed. R. Civ. P. solely as it pertains to thebaseless insinuations and accusations he has made concerning my alleged involvement inor knowledge of purported wrongful conduct concerning my former firm, SNR Denton,
formerly Sonnenschein Nath & Rosenthal ("Sonnenschein") in connection withSonnenschein's prior representation of Mr. Rowe as Plaintiff in the above-captioned
action.
3.
In his
pro se
Rule 60 Motion, Mr. Rowe insinuates that I was somehow involved in orhad knowledge of an alleged "cover-up" of evidence of racial discrimination in the musicindustry. The apparent gist of Mr. Rowe's contention is that sometime in July of 2002,
while Sonnenschein was representing Mr. Rowe, the defendants in this case supposedlyproduced to Sonnenschein in discovery more than 200 e-mails which allegedly contained
4627853.1
 
the "n"-word nearly 400 times.
1
According to Mr. Rowe, Sormenschein attorneys Martin
Gold and Ray Heslin engaged in some kind of conspiracy with the defendants to concealthese emails from Plaintiffs in order to hurt their case, as part of some purported broaderconspiracy to perpetuate racism in the music industry.
4.
These accusations against my former Sonnenschein partners are patently preposterous to
me. Certainly, I have no knowledge of any such conduct, never engaged in or assisted in
such conduct, and have absolutely no reason to believe that there is a shred of truth to
these contentions.
5.Mr. Rowe's supporting declaration specifically mentions me in connection with any
alleged fact only once, in only one sentence in one paragraph, which reads in its entirety
as follows:
"Attorneys Martin Gold, Ray Heslin, Richard Primoff, Christine Lepera
and Carl Aron, after taking over $200,000 for email discovery andcompelling us to wait, patiently, attorneys Gold, Heslin, Prirnoff andLepera advised that nothing had been found as a result of the emails
searched. When this was reported to me, I could tell that Mr. Gold, Mr.
Primoff, and Mr. Heslin were not being truthful but I had no proof at that
time. (DeclarationT 9)
6.
I have no recollection of any such communication, nor any knowledge of emails that are
of the nature described vaguely by Mr. Rowe's motion. I was not involved in email
discovery and the details of that process.
7.
To the extent that Mr. Rowe is insinuating that I had any knowledge of or participation in
his theoretical "conspiracy" his insinuation is wholly fabricated. It is in fact outrageous
1
In 2010 Mr. Rowe published a book entitled "What Really Happened to Michael Jackson the King of Pop, The
Evil Side of the Entertainment Industry" (" Rowe's Book" ) At pages 89 —91 of his book Mr. Rowe wrote that he
learned about these "emails" in this case in July of 2002.
See
title and relevant pages attached hereto as Ex. A.
4627853.1
 
in the extreme for Mr. Rowe to suggest any such thing, which is wholly defamatory, and
to which I take great offense. His insinuations and accusations are completely and
categorically untrue.
8.
Indeed, Mr. Rowe knows full well that I provided and he received dedicated and loyal
counsel. When his book was published in 2010, Mr. Rowe sent me a copy enclosing a
personal handwritten note which says: "I hope all is well. I thought you should have this
[the Rowe Book]. I truly thank you for the good job you was always trying to do."
Signed Leonard Rowe.
See
Exhibit "C" attached hereto. Needless to say, the book is
highly disturbing and offensive (see below), but it makes no mention of any of theinsinuations made against me in this motion.
9.
Then, out of the blue this year, on February 28, 2012, I received a letter addressed to mefrom Mr. Rowe which states in entirely cryptic fashion that he has been:"guided to formally present issues that were never presented to the FirstDepartment attorney grievance committee [in a proceeding he states thathe initiated against Messrs. Gold and Heslin] nor, in fact to the USDepartment of Justice [and] your name came up as someone who
witnessed a variety of troubling events""I am asking you to relay to me in writing your position regarding thewillful failing of Messrs. Gold and Heslin to report the federal crimes ofwhich they had knowledge of at all times while involved in the RoweEntertainment Case (SDNY 98-civ-8272)". (Exhibit D hereto)10.
I had and have no idea of what he was talking about, including when he said "my name
came up" as a witness to some undefined "variety of troubling events" and when hewrote of purported "federal crimes". I certainly never witnessed anything remotelytroubling, no less "criminal". This letter was very disturbing in that it smacked of a
4627853.1
 

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